Horton v. Centurion of Tennessee, LLC, 1:23-cv-01239

Background

Plaintiff, Joshua Horton, an inmate in Tennessee’s correctional system, alleged he received inadequate medical care from contracted medical staff at Northwest Correctional Complex, resulting in delayed diagnosis of a spinal epidural abscess that caused permanent paralysis.
He brought claims against two individual providers (Dr. Guerrant and Nurse Practitioner Hendrix-Labonte), their employer Centurion, TDOC, and others for deliberate indifference under 42 U.S.C. § 1983 (Eighth Amendment) and for medical negligence under Tennessee state law.
The undisputed facts showed Horton repeatedly sought medical care for escalating back pain, with symptoms worsening from October through December 2022; ultimately, his spinal infection was diagnosed only after he became paralyzed and incontinent.
Medical staff generally responded to Horton’s sick call requests (SCRs); during the relevant period, several providers, including the defendants, administered testing and pain management, but did not recognize the abscess until late.
The providers' diagnostic efforts included imaging and referrals, but an MRI authorization was denied for documentation reasons. When eventually performed, imaging revealed the severe infection, but irreversible injury had occurred.
At summary judgment, the court assessed whether the conduct amounted to "deliberate indifference" or was, even if negligent, below the constitutional threshold.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deliberate indifference under § 1983 (Eighth Amendment)	Providers knowingly disregarded worsening symptoms between Dec. 5–8, 2022, failing to diagnose and urgently treat spinal infection, showing deliberate indifference.	Medical staff consistently responded to SCRs, provided ongoing care, misdiagnosis/negligence not equal to deliberate indifference; no evidence they drew and ignored inference of serious risk.	No deliberate indifference; misdiagnosis/negligence not enough; summary judgment for defendants.
Monell liability against Centurion under § 1983	Centurion had custom/policy of delayed specialty care, over-reliance on conservative treatment, and inadequate supervision causing plaintiff’s injury.	No constitutional violation by individual defendants; plaintiff failed to identify specific Centurion policy/custom as moving force; isolated incident, not policy.	No Monell liability; summary judgment for Centurion.
State law medical negligence claims	Providers' actions fell far below state standard of care, as shown by expert opinions, and caused harm.	Plaintiff’s experts do not satisfy the locality rule under TN law; insufficient expert proof of standard of care in relevant community.	Court declines supplemental jurisdiction after dismissing federal claims; state claims dismissed without prejudice.
Plaintiff’s motion for summary judgment	Evidence clear that providers’ actions were grossly inadequate and warrants judgment as a matter of law for plaintiff.	Plaintiff cannot show care was so grossly inadequate as to shock the conscience or no treatment at all; some care always provided.	Plaintiff’s motion for summary judgment denied.

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (Deliberate indifference standard for prisoner medical care under Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (Objective and subjective components for Eighth Amendment deliberate indifference)
Monell v. Department of Social Services, 436 U.S. 658 (Municipal liability under § 1983 requires policy or custom causing injury)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Summary judgment standard)
Celotex Corp. v. Catrett, 477 U.S. 317 (Summary judgment burden of proof)
Rhinehart v. Scutt, 894 F.3d 721 (Medical care must be so grossly inadequate as to "shock the conscience" for Eighth Amendment violation)